United States Court of Appeals for the First Circuit
41 F.3d 775 (1st Cir. 1994)
Hector Julio Felix Montas (defendant) was charged with possession with intent to distribute cocaine. A customs K-9 unit had detected cocaine in his luggage at the airport, although the luggage had a different name on the tags. At trial, the prosecution called DEA agent Ivan Rios as a witness. Rios gave his opinion and experiences with similar drug cases involving airport luggage. Specifically, Rios testified that individuals smuggling drugs generally do not use their real names on their plane tickets and luggage. Montas objected at various times throughout Rios’s testimony on the grounds of speculation, relevance, and leading questions. The objections were overruled. The jury convicted Montas. He appealed on the grounds that the court improperly admitted Rios’s expert testimony because the testimony “concerned a subject within an average juror’s understanding.”
Rule of Law
Holding and Reasoning (Coffin, S.J.)
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